American Disability Act Ruling

The U.S. Circuit Court of Appeals for the Eleventh Circuit yesterday articulated what it means to be “disabled” under the Americans with Disabilities Act when it affirmed a judgment in favor of an employer sued by a former employee who alleged she was fired because of her “disability.” The ADA defines “disability” three ways. An individual is “disabled” if she (1) has a physical or mental impairment that substantially limits one or more of her major life activities; (2) has a record of such an impairment; or (3) is regarded as having such an impairment.

The employee had been diagnosed with anemia but testified the anemia never impaired any major life activity and that she only informed her employer of her diagnosis after she was fired. She never requested a reasonable accommodation from her employer. She never provided her managers with any documents related to her condition. Thus, she had failed to establish a “disability” under the ADA.